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The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures

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  • Borkowski, Susan C.

Abstract

In its 25 years of existence, the Pacific Association of Tax Administrators (PATA) has attempted to protect tax revenues and combat tax evasion techniques (including transfer pricing) by transnational corporations (TNCs). To that end, the tax authorities of its four member countries (Australia, Canada, Japan and the United States) have met at least annually to exchange information and identify specific deterrents to tax evasion activities that could be implemented quickly. Recently, PATA has released several documents to assist both tax authorities and TNCs in the area of advance pricing agreements, mutual agreement procedures, and transfer-pricing documentation. The study looks at the PATA's influence on tax authorities and TNC behavior in these and other areas.

Suggested Citation

  • Borkowski, Susan C., 2008. "The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 17(1), pages 31-50.
    • Handle: RePEc:eee:jiaata:v:17:y:2008:i:1:p:31-50
    DOI: 10.1016/j.intaccaudtax.2008.01.004
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    Cited by:

    1. Borkowski, Susan C., 2010. "Transfer pricing practices of transnational corporations in PATA countries," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 19(1), pages 35-54.
    2. Dykxhoorn, Hans J. & Sinning, Kathleen E., 2010. "A review and analysis of international accounting research in JIAAT: 2002–2010," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 19(2), pages 137-153.
    3. Borkowski, Susan C. & Gaffney, Mary Anne, 2012. "FIN 48, uncertainty and transfer pricing: (Im)Perfect together?," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 21(1), pages 32-51.
    4. Kortebusch, Pia, 2014. "Should multinational companies request an advance pricing agreement (APA) - or shouldn't they?," arqus Discussion Papers in Quantitative Tax Research 173, arqus - Arbeitskreis Quantitative Steuerlehre.

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    Keywords

    Transfer pricing; International taxation;

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